HomeMy WebLinkAboutAQ_F_1900015_20190328_CMPL_InspRpt (4) wij
NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY Arauco North America,Inc.
NC Facility ID 1900015
Inspection Report County/FIPS: Chatham/037
Date: 03/28/2019
Facility Data Permit Data
Arauco North America,Inc. Permit 03449/T51
985 Corinth Road Issued 3/6/2019
Moncure,NC 27559 Expires 6/30/2021
Lat: 35d 36.0910m Long: 79d 2.6020m Class/Status Title V
SIC: 2493/Reconstituted Wood Products Permit Status Active
NAICS: 321219/Reconstituted Wood Product Manufacturing Current Permit Application(s)TV-Minor
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/PSD
Yvonne Couts Jeff McMillian Yvonne Couts MACT Part 63: Subpart DDDD,Subpart
Environmental Manager Plant Manager Environmental Manager DDDDD,Subpart ZZZZNSPS: Subpart Dc,Subpart IIII
(919)545-5848 (919)545-5865 (919)545-5848
Compliance Data
Comments: In Compliance
Inspection Date 03/28/2019
�i,� Inspector's Name Matthew Mahler
Inspector's Signature: �j�� �l Operating Status Operating
�( Compliance Code Violation-emissions
12—,ol
ction Code FCE
Date of Signature: /0/ 2-9y q On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *IIAP
2017 124.14 12.64 216.83 708.04 340.86 123.16 350114.49
2016 126.44 14.52 241.64 597.49 389.07 123.90 255023.10
2015 185.68 12.64 296.93 793.10 518.43 182.48 81546.00
*Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
04/20/2017 NOV/NRE 2D.0521 Control of Visible Emissions 05/12/2017
04/20/2017 NOV/NRE 2Q.0317 Avoidance Conditions 05/12/2017
04/20/2017 NOV/NRE 2D .1111 Maximum Achievable Control Technology 05/12/2017
04/20/2017 NOV/NRE 2D.0530 Prevention of Significant Deterioration 05/12/2017
04/20/2017 NOV/NRE 2D .0512 Particulates from Wood Products Finishing 05/12/2017
Plants
10/12/2016 NOV/NRE Permit Permit Condition 11/04/2016
10/12/2016 NOV/NRE 2D.0512 Particulates from Wood Products Finishing 11/04/2016
Plants
10/12/2016 NOV/NRE 2D .0521 Control of Visible Emissions I1/04/2016
10/12/2016 NOV/NRE 2D .0515 Particulates from Miscellaneous Industrial 11/04/2016
Processes
10/12/2016 NOV/NRE 2Q.0317 Avoidance Conditions 11/04/2016
10/23/2015 NOV/NRE Part 63-NESHAP/MACT Subpart DDDD Plywood and Pending
Com osite Wood Products
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
11/08/2018 Compliance NCASI METHOD Cl/WP 98.01 ES-01,ES-02-A,ES-02-B,ES-02-
C-1,ES-02-C-2,ES-02-D,ES-06-
B,ES-16
(I) DIRECTIONS: Arauco Panels USA is located at 985 Corinth Road, Moncure,NC, Chatham County. From
Raleigh, take US-1 South toward Sanford. Just over the Chatham County line, exit onto Old US-1 (SR-1011)
and turn south(right). Travel approximately 3 miles, turn left onto Corinth Road(SR-1916), and the plant will
be approximately 1/2 mile on the left. Sign in at the log cabin.
(II) FACILITY DESCRIPTION: Arauco Panels USA LLC manufactures medium density fiberboard (MDF)
and particleboard(PB),both of which are primarily sold to the furniture and flooring industry. The facility runs
seven days a week using two 12-hour shifts. At the time of the inspection the facility was staffed by
approximately 291 employees. Standard safety equipment is sufficient at this facility. Due to truck traffic, be
cautious when walking outside around the plant grounds.
The MDF plant was built from new and refurbished equipment. Some of the refurbished equipment originated
from a closed plant in Quebec. The MDF plant can also produce high density fiberboard (HDF). When making
the p I ant uses o southern pine chips according to the stalT Hljk is o har-dwood and the balance is
pine. The HDF is mainly used for flooring. The MDF/HDF plants utilize wood chips to form the boards. The
first MDF board from the new plant was processed on February 17, 2010.
The MDF/HDF and the particleboard plants have historically used urea formaldehyde resin to serve as a
bonding agent but during the past few years, the facility has been experimenting with using diphenylmethane
diisocyanate(MDI) as bonding agent. MDI, when used in this application, is thought to generate less off-
gassing emissions as compared to the urea formaldehyde resins. At this point, neither plant has been able to
utilize MDI without the board quality being compromised.
The first MDF board from the new plant was processed on February 17, 2010. The particleboard products are
composed of wood chips, shavings, and saw dust. Particleboard consists of three layers: surface layer, core
layer, and surface layer. The outside surface layers are comprised of sawdust that is approximately 20%
hardwood/80%pine. The core layer is comprised of chip flakes that are also approximately 20%
hardwood/80%pine. In both the MDF and PB plants, the boards are pressed to varying thicknesses and widths.
The continuous MDF press is able to form boards with thickness ranging from 3.0 mm to 28 mm and with
widths from 2.45 to 3.15 meters (8 to 10.3 feet). The particleboard plant produces sheets that are typically 5
feet wide by 9 feet long. A previous inspection report indicated that this plant produces particleboard ranging in
thickness from V2"to 1 1/". The MDF and particleboard presses operate at 500°F and 350°F respectively.
(III) INSPECTION SUMMARY: On March 28, 2019, Mr. Ray Stewart, Raleigh Regional Supervisor, and I
(Matt Mahler) arrived to perform a compliance inspection at 9:15 am. The Facility Contact, Ms. Yvonne Couts,
Environmental Manager, was away from the site. She had recently been promoted from Environmental
Coordinator to Environmental Manager. Mr. John Bird,North America Environmental Manager,met us in the
lobby of the log cabin building at 10:00 am. Ms. Couts joined us later during the earlier portion of the site tour.
We began the inspection by touring both the MDF plant and then the particleboard plant. Both plants were in
operation. Some visible emissions were observed from the particleboard press and dryer stacks. The VE
observed for both emission points appeared to be between 15%-20% opacity. However, it should be noted that
the sun angle was overhead at the time. The particleboard plant dryers have historically had fairly high visible
emissions exhausting from their stack. Overall, the facility appeared to be well maintained and being operated
in accordance with air quality regulations. Afterwards, we returned to the facility's administration building to
complete a record review. The records appeared to be well maintained and mostly complete. Ms. Couts had to
leave the site for a personal appointment before the end of the inspection. Mr. Bird stated that he would follow-
up with the RRO after the inspection and forward the missing recordkeeping by email.
(IV) PERMITTED EMISSION SOURCES: At the time of this inspection, Arauco was operating under Air
Permit No. 03449T51, which became effective on March 6, 2019, expires on June 30, 2021, and includes the
following emission sources and control devices:
A. Material Handling Sources:
Truck/rail chip handling system (ID No. 7001 or SP-1);
-Truck/rail sawdust handling system (ID No. 7004 or SP-2);
-Particleboard mill truck dump (ID No. 7010);
-Dump bunkers and CL dryer dump (ID Nos. 7012, 7014, 7015, and 7029);
-Wood residue bunkers (ID Nos. 7052, 7054, 7055 and 7056);
-Wood chip piles -medium density fiberboard mill (ID Nos. 6001, 7002 A, 7002-B, 7002-C,
and 7002 D);
-Wood fuel pad and boiler transfers (ID Nos. 6003, 7006, 7007, 7022);
-Sawdust transport to A frame (ID Nos. 7005-D, 7005-E, 7005-F, 7005-G);
-Fuel sawdust and chip storage piles (ID No. SP);
-Scale transfer conveyors (ID No. 7025);
-Fiber dump and reject filter bins (ID Nos. 7019 and 7026);
-Hog fuel hopper (ID No. 7027);
-Particleboard mill chip transfer (ID Nos. 7040, 7044, 7046, 7048, and 7050); and
-Particleboard mill feed lines (ID No. 7024).
B.Medium Density Fiberboard Mill:
-Refiner (ID No. ES-01) and associated refiner abort cyclone (ID No. CD-01) and two
venturi/packed bed scrubbers (ID Nos. CD-02, CD-14);
-Three natural gas-fired hot oil heaters (24 mm/Btu per hour, ID Nos. ES 18, 19, 20);
-Energy System consisting of one dry/wet woodwaste-fired burner (205mm Btu per hour, ID
No. ES02 A) controlled by one Urea/water injection system (ID No. CD-02A) and two
venturi/packed bed scrubbers (ID Nos. CD-02, CD-14);
-Two stage dryer system (ID No. ES-02-B) and two backup natural gas-fired dryer burners
(78.5 and 17 mm Btu per hour, ID Nos. ES-02-C, ES-02-D);
-MDF Press (ID ES-16) controlled by one venturi/packed bed scrubber (ID No. CD-16);
-MDF Board Cooler (ID ES-06-B) controlled by two venturi/packed bed scrubbers (ID
Nos. CD-02, CD-14);
-Fiber Sifter System (ID No. ES-03) controlled by one fabric filter (ID No. CD03);
-Forming Line Clean-Up System (ID No. ES-04) controlled by one fabric filter(ID No.
CD04);
-Mat Reject System (ID No. ES-05) controlled by controlled by one fabric filter(ID No.
CD05);
-Saw System (ID No. ES-07) controlled by one fabric filter(ID No. CD07);
-Sander System No. 1 (ID No. ES-08) controlled by one fabric filter(ID No. CD08);
-Recycled Fiber Silo No. 1 (ID No. ES-09) controlled by bin vent filter (ID No. CD09);
-Sander System No. 2 (ID No. ES-10) controlled by one fabric filter(ID No. CD10);
-Sander Dust Silo No. 1 (ID No. ES-12) controlled by bin vent filter (ID No. CD12);
-Dry Sawdust Silo (ID No. ES-13) controlled by one bin vent (ID No. CD13);
-Recycled Fiber Silo No. 2 (ID No. ES-15) controlled by one bin vent filter(ID No. CD15);
-Sander Dust Silo No. 2 (ID No. ES-17) controlled by one bin vent filter(ID No. CD17);
-Four MDF resin storage tanks (ID Nos. MDFR-1, MDFR-2, MDFR-3, MDFR-4);
-Diesel Fuel-Fired Emergency Generator (1592 Brake Horsepower output) (ID ES-21);
C. Particleboard Mill.
-Sawdust rock and metal separator(ID No. 3501) and associated cyclone (ID No. CD-SC)
and bag/ilter(ID No. CD-3501);
-Surface layer dryer (ID No. 1430) and associated multicyclone (ID No. CD-1431; 60
million Btu per hour maximum rated heat input), wet electrostatic precipitator(ID No..
CD-PB-WESP), and packed bed scrubber (ID No. CD-PB-PGT);
-Core layer dryer No. 1 (ID No. 1420) and associated multicyclone (ID No. CD-1421; 50
million Btu per hour maximum rated heat input), wet electrostatic precipitator (ID No.
CD-PB-WESP), and packed bed scrubber (ID No. CD-PB-PGT);
-Core layer dryer No. 2 (ID No. 1410) and associated multicyclone (ID No. CD-1411; 50
million Btu per hour maximum rated heat input), wet electrostatic precipitator (ID No.
CD-PB-WESP), and packed bed scrubber (ID No. CD-PB-PGT);
-Wellons wood suspension dust-fired burner(ID No. 3201; 40 million Btu per hour
maximum rated heat input) exhausting to either surface layer triple pass, rotary drum
(#3) dryer[ID No. 1430] and/or core layer single pass, rotary drum (#1) dryer[ID
No. 1420] and/or core layer single pass, rotary drum (#2) dryer[ID No. 1410];
-Surface material transport (ID No. 3515) and associated cyclones (ID Nos. CD-3500 &
CD-3512-B) and bagfilter(ID No. CD-3515);
-Surface formers and mat dumps (ID No. 3525) and associated cyclones (ID Nos. CD-3520-
A, CD-3520-B, & CD-3521) and bagfilter (ID No. CD-3525);
-Flying cut off saw,pretrim saws, and production collection (ID No. 3535) and associated
cyclones (ID Nos. CD-3530, CD-3531, & CD-3533) and bagfilter (ID No. CD-3535);
-Particleboard press (ID No. DEF-2010) controlled by dryer (ID No. 1430 or No. 1420)
and associated multicyclone (ID No. CD-1431 or CD-1421); 60 million Btu per hour
maximum rated heat input), wet electrostatic precipitator (ID No. CD-PB-WESP), and
packed bed scrubber (ID No. CD-PB-PGT);
-Particleboard cooler (ID No. PB-BC);
-Particleboard Steinemann calibrating sander (ID No. 3565) and associated cyclone (ID
Nos. CD-3570) and bagfilters (ID No. 5001 & CD-3575);
-Particleboard Steinemann finishing sander (ID No. 3545) and associated cyclone (ID Nos.
CD-3570) and bagfa'lters (ID No. 3545 & CD-3575);
-Schelling saw board trim (ID No. 3555) and associated cyclone (ID No. CD-3522) and
bagfilter (ID No. CD-3555);
-Sander filter transport for filters 3545 and 3565 (ID No. 3575) and associated cyclone (ID
No. CD-3570) and bagfilter (ID No. CD-3575);
-PZKR green chip flakers (ID No. 3585) and associated bagfilter (ID No. CD-3585);
-Oversized material Pallmann mill (ID No. 3595) and associated bagfilter (ID No. CD-
3595); and
-Dry waste transport system (ID No. 3577) and associated cyclone (ID No. CD-3532) and
bagfilter (ID No. CD-3577;
-Diesel Fuel-fired Fire Pump Engine (347 Brake Horsepower output) (ID ES-DFP-1);
-Diesel Fuel-fired Emergency Generator (465 Brake Horsepower output) (ID ES-ODG).
D. Laminating Mill.
-Two short cycle laminating presses (ID Nos. 3593 &3594) and associated bagfilter (ID
No. CD-3593); and
-Natural gas and No. 2 oil-fired thermal oil heater (ID No. Pr-Heatl).
The MDF and the particleboard plants were operating at the time of the inspection. All facility emission
sources were observed and most sources in the MDF and particleboard plants were in operation. The
particleboard plant operates at a reduced schedule of approximately two days every other week. As indicated
in previous inspection reports, one of the two particleboard core layer dryers (ID No. 1410) is inoperable.
This dryer was severely damaged in a 2007 fire and has been removed from the permit. The facility continues
to operate with two particleboard dryers - one surface layer dryer and one core layer dryer. The laminating
mill was decommissioned on December 8, 2016 and resumed operation in May 2018. The wastewater
evaporator, ID No. EVAP-1, was decommissioned in August 2017. Mr. Bird was unable to locate all of the
sources in the material handling sources permitted equipment list. Mr. Bird stated that this list needs to be
cleaned up of outdated sources during the next permit revision. He noted that the Wood Fuel Pad and Boiler
Transfers are no longer used since the Wellons no longer combusts wood. The Hog Fuel Hopper in the MDF
plant is also no longer used. Overall, the equipment appeared to be adequately maintained.
(V) PERMIT STIPULATIONS: As is the case with all Title V permits,Air Quality Permit No. 03449T49 lists
all of the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in
this report, the applicable air quality regulations are discussed individually, and all of the permitted emission
sources that are subject to a specific regulation are noted.
(1) 15A NCAC 2D.0503: PARTICULATES FROM FUEL B URNING INDIRECT HEAT EXCHANGERS- The
following emission sources are subject to 2D .0503: The thermal oil heaters (MDF Plant—ID Nos. ES-I8, ES-
19, ES- 20), thermal oil heater (Laminating Plant-ID No. Pr-Heat]), and Wellons (ID No. 3201) during OS2
(natural gas fueled- exhausting to atmosphere).
IN COMPLIANCE - The particulate emission limit for the subject sources when burning natural gas or fuel oil
is 0.35 pounds per million Btu heat input for the MDF plant thermal oil heaters and 0.60 pounds per million Btu
heat input for the particleboard thermal oil heater. When these combustion sources are burning natural gas or
fuel oil, the 15A NCAC 2D .0503 particulate emissions standard should be achieved during normal operating
conditions. To estimate the degree of compliance, emission factors from the NC DAQ's Fuel Oil Combustion
Spreadsheet were used. The estimated particulate emission rate for No. 2 fuel oil combustion in these units
would be 0.034 pounds per million Btu, well below the limit. Particulate emission rate from natural gas
combustion would be significantly less than the emissions from fuel oil combustion.
No particulate emission testing is required by this regulation. Additionally, no monitoring/record
keeping/reporting is required for particulate emissions from the firing of natural gas or fuel oil in these
combustion sources.
(2) 15A NCAC 2D.0504: PARTICULATES FROM WOOD BURNING INDIRECT HEAT EXCHANGERS- The
following emission source is subject to 2D .0504: The Wellons burner (ID No. 3201) during OSl (exhausting to
dryers).
IN COMPLIANCE—The facility installed a natural gas burner on the Wellons burner and is now burning
exclusively natural gas. During a previous inspection, Mr. Bird stated that it would be difficult to burn wood in
the Wellons, the way that the equipment is laid out. Natural gas combustion is typically a clean process
generating low levels of particulates. Compliance is expected.
(3) 15A NCAC 2D .0512: PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING
PLANTS— The following emission sources are subject to 2D .0512: Fiber Sifter System (ID No. ES-03),
Forming Line Clean-Up System (ID No. ES-04), Mat Reject System (ID No. ES-05), Saw System (ID No. ES-
07), Sander System No. 1 (ID No. ES-08), Recycled Fiber Silo No. (ID No. ES-09), Sander System No. 2 (ID No.
ES-10), Sander Dust Silo No. 1 (ID No. ES-12), Dry Sawdust Silo (ID No. ES-13), Recycled Fiber Silo No. 2
(ID No. ES-15), Sander Dust Silo No. 2 (ID No. ES-17), Sawdust Rock and Metal Separator(ID No. 3501),
Surface Material Transport(ID No. 3515), Surface Formers and Mat Dumps (ID No. 3525), Flying Cut Saw,
Pretrim Saws, &Production Collection (ID No. 3535), Particleboard Press (ID No. DEF-2010), Particleboard
Cooler (ID No. PB-BC), Particleboard Mill Steinemann Calibrating Sander(ID No. 3565), Particleboard Mill
Steinemann Finishing Sander (ID No. 3545), Schelling Saw Board Trim (ID No. 3555), Sander Filter Transport
for Filters 3545 and 3565 (ID No. 3575), PZKR Green Chip Makers (ID No. 3585), Dry Waste Transport
System (ID No. 3577), Oversized Material Pallmann Mill(ID No. 3595).
IN COMPLIANCE - In accordance with 15A NCAC 2D .0512, the permittee shall not cause, allow, or permit
particulate matter caused by the working, sanding, or finishing of wood to be discharged from any stack, vent,
or building into the atmosphere without providing, as a minimum for its collection, adequate duct work and
properly designed collectors. To comply with this regulation, the facility must conduct monthly and annual
inspections of the ductwork and control devices,record the results of these inspections in a logbook, and submit
a deviation report to DAQ on a semiannual basis. A review of the records indicated that the facility had
performed the required monthly and annual inspections since the last DAQ inspection. The particleboard plant
annual inspections are spread throughout the year. The most recent particleboard plant and MDF plant annual
inspections were conducted in October 2017. The next particleboard and MDF annual inspections are
scheduled to take place in October 2018.
During the plant tour, observations indicated that the ductwork and control devices appeared to be in good
physical condition. No emission source subject to 15A NCAC 2D .0512 was observed in operation without its
respective control device. The submission of semiannual reports has been performed as prescribed in the
permit.
(4) 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEO US IND USTRIAL PROCESSES- The
following emission sources are subject to 2D.0515:Refiner (ID ES-01), Energy System (ID ES-02-A), Two
stage dryer system and backup dryer burners (ID ES-02-B, ES-02-C, ES-02-D), MDF Board Cooler (ID ES-06-
B), MDF Press (ID ES-16), PB surface layer dryer(ID No. 1430), PB core layer dryer No. I (ID No. 1420), PB
core layer dryer No. 2 (ID No. 1410), and the short cycle laminating presses (ID Nos. 3593 & 3594).
IN COMPLIANCE - The particulate emission limit for each of the subject emission sources is determined based
on the individual process throughput(weight) rates for each source. The PB surface layer dryer(ID No. 1430)
and one of the PB core layer dryers (ID No. 1420) was tested on October 22, 2009. During the test, the lowest
throughput of material passing through these two dryers was 97,350 lb/hr. Using this lower throughput rate
ensures the lowest calculated particulate limit. Using the applicable formula associated with the regulation, the
calculated particulate limit for this unit is 55.37 lb/hr. The performance results from the October 22, 2009 test
indicated that the particulate emission rate for the combined dryer exhaust stack was 8.891b/hr. This emission
rate is well below the 15A NCAC 2D .0515 particulate emissions standard.
The MDF plant installed control devices throughout the facility to help meet applicable emission standards.
The facility installed two parallel sets of venturi/packed bed scrubber combinations (CD02, CD14). These units
are connected to the refiners, the main energy system, the two-stage dryer system, and the board cooler. The
plant also installed a venturi/packed bed scrubber system to the MDF press (CD16). The venturi scrubbers are
primarily particulate control devices. To help monitor the efficiency of these venturi scrubbers, the permit
requires that 3-hour block averages be recorded on the pressure drop and the recirculating liquid flow of the
units.
The facility has discontinued the use of the photochemical gas treatment (PGT)unit due to a number of
problems. The venturi scrubbers are still operational.
According to a November 4, 2014 MDF dryers stack test report, the process rate was 67.32 tons per hour and
the total particulate emission rate was 15.32 pounds per hour. Using the equation for processes with
throughputs greater than 30 tons per hour, the calculated emission limit according to 2D .0515 is 47.39 pounds
per hour. The MDF Energy System/dryers are required to perform annual particulate testing(at emission points
- EP02, EP 14). If the results of the test are less than 80% of the limit, the testing frequency can be changed
from annual to every five years. The test results of 15.32 lb/hr is 32% of the limit (47.39 lb/hr).
The MDF plant has been conducting trials using a biofiltration system for the MDF plant.
The laminating mill is also regulated by 2D .0515. The processes in the laminating mill do not produce large
amounts of particulates. There is a bagfilter controlling emissions from the mill. Note that the laminating mill
has been decommissioned.
To ensure ongoing compliance with the 15A NCAC 21) .0515 emissions standard,the permit requires that the
each of the subject emission sources be controlled by the associated particulate control devices (cyclones,
multicyclones, Wet ESP, and wet scrubber) as listed in the permit during all periods of operation. All the
particulate control devices that were observed during the inspection appeared to be in good physical condition,
and no emission source was observed in operation without its respective particulate control device. The permit
does require the facility to perform monthly and annual inspections of the laminating mill bagfilter in addition
to regular maintenance activities. Upon request, the facility was able to provide records that demonstrated that
the required monitoring and recordkeeping was being conducted as described in the permit. The submission of
semiannual reports has been performed as prescribed in the permit.
(5) 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- The following
emission sources are subject to 2D.0516: The thermal oil heaters (MDF Plant—ID Nos. ES-18, ES-19, ES-20),
PB surface layer dryer (ID No. 1430), PB core layer dryer No. 1 (ID No. 1420), PB core layer dryer No. 2 (ID
No. 1410), Wellons burner (ID No. 3201), thermal oil heater (ID No. Pr-Heatl), emergency generator(ES-21),
and emergency generator (ES-ODG).
IN COMPLIANCE- The sulfur dioxide emission limit for each of the subject emission sources is 2.3 pounds
per million Btu heat input. Since the facility burns exclusively natural gas,No. 2 fuel oil, and wood fuel in its
combustion equipment, the 15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved during
normal operating conditions. No sulfur dioxide emission testing is required by the facility's air permit.
Additionally, no monitoring/record keeping/reporting is required for sulfur dioxide emissions from the firing of
natural gas, fuel oil, or wood fuel in the combustion units.
(6) 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS-All of the permitted emission sources are
subject to 2D.0521.
IN COMPLIANCE- The visible emission limit for all plant emission sources is 20 percent opacity. Visible
emissions testing(Method 9) is not required by the facility's air permit. The permit does require the facility to
perform visible emission observations (checking for above-normal opacity) on the affected equipment, record
the results of the evaluations in a logbook, and submit a summary report of the observations on a semiannual
basis. If the opacity appears above-normal, the facility is required to either correct the condition causing the
above-normal visible emissions or to perform an official Method 9 test to determine the opacity of the plume.
During the record reviews of the visible emission observations of the MDF dryers and the particleboard dryers'
emission points, all weekly observations indicated that no opacity was logged at being over 20%. The
submission of semiannual reports has been performed as prescribed in the permit.
According to the air permit, weekly visible emissions monitoring is required for most of the applicable sources.
The permittee was previously required to monitor the Energy System (ID ES-02-A) exhaust for opacity daily
but the current permit revision allows for weekly observations. It appeared that all the opacity readings were
being performed as required.
(7) 15A NCAC 2D.0524: NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart Dc): The
following emission sources are subject to 2D .0524:Hot Oil Heaters (ID ES-18, ES-19, ES-20).
IN COMPLIANCE- As with other NSPS regulations, applicable sources are required to give construction and
startup notifications. The construction notification was sent in April 2009. The startup notification was sent in
January 2010. The only other requirement for this unit under this regulation is recording the monthly fuel
usage. The MDF plant has only one gas meter that measures fuel usage for both the backup gas dryer burners
and the three Ness burners (hot oil heaters). Usually when the Ness burners are operating, the backup dryer
burners are also operating. When both units are operating, the fuel usage for individual units can be estimated
by using the known fuel usage ratios for the dryer and the hot oil heaters. The facility is tracking daily fuel
usage for the MDF plant.
(8) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart IIII): The
following emission sources are subject to 2D.0524:Fire Pump Engine (ID DFP-1).
IN COMPLIANCE—The fire pump engine is rated at 347 horsepower. The facility had submitted
manufacturer's data that certifies this unit can meet Tier 3 standards and is in compliance with the NSPS
standards for its size. In a previous inspection, the facility presented fuel provider data sheets that indicate that
the sulfur level is 15 ppm in the diesel fuel. The pump engine has a non-resettable hour meter installed on it.
According to the facility records, the fire pump had 440.0 hours on the hour meter during the September 26,
2017 inspection and 467.4 hours during this inspection.
(9) 15A NCAC 2D .053 0: PREVENTION OF SIGNIFICANT DETERIORATION(PSD)— The following
emission sources are subject to 2D.0530:PB surface layer dryer (ID No. 1430), PB core layer dryer No. I (ID
No. 1420), PB core layer dryer No. 2 (ID No. 1410), Sawdust Rock and Metal Separator (ID No. 3501), Surface
Material Transport(ID No. 3515), Surface Formers and Mat Dumps (ID No. 3525), Flying Cut Saw, Pretrim
Saws, &Production Collection (ID No. 3535), Particleboard Press (ID No. DEF-2010), Particleboard Cooler
(ID No. PB-BC), Particleboard Mill Steinemann Calibrating Sander (ID No. 3565), Particleboard Mill
Steinemann Finishing Sander (ID No. 3545), Schelling Saw Board Trim (ID No. 3522), Sander Filter Transport
for Filters 3545 and 3565 (ID No. 3575), PZKR Green Chip Flakers (ID No. 3585), Dry Waste Transport
System (ID No. 3577), and Oversized Material Pallmann Mill(ID No. 3595).
IN COMPLIANCE -The various sources of the particleboard plant have established PMlo, volatile organic
compound, and opacity limits. Overall, to ensure compliance with 15A NCAC 2D .0530, the permit limits total
particleboard production to 180,000,000 square feet per year on a 3/-inch basis and a limit to the operating
hours of each of the particleboard dryers (8,500 hours). According to the 1"2018 semiannual report,the
highest 12-month rolling total particleboard production rate in that 6-month period was 105,887,000 square feet
on a 3/-inch basis (July 2017—June 2018). Similarly, the highest 12-month rolling total number of dryer hours
in that 6-month period was the surface layer dryer at 4,715 hours (July 2017—June 2018). Recordkeeping of the
maintenance perforined on woodworking operations sources was observed as SAP work orders.
The permit lists specific Best Available Control Technology(BACT) limits for each of the subject emission
sources. The PB surface layer dryer(ID No. 1430) and one of the PB core layer dryers (ID No. 1420) was
tested in October 22, 2009 and the results from this testing demonstrated that particulate emissions, volatile
organic compounds, visible emissions, carbon monoxide, and nitrogen oxides from the operating PB dryers
were below the BACT standards. The core layer dryer(ID No. 1410) that was destroyed in a 2007 fire will
need to be tested within 90 days of repair and startup. There are no current plans to restart this dryer.
The permit also specifies that none of the subject emission sources should be operated without their respective
control devices also in operation. Each type of control device has specific testing,monitoring, record keeping,
and reporting requirements outlined in the permit. One of the requirements is that the cyclones and
multicyclones (CD-1421, 1431)be visually inspected monthly. As with the 15A NCAC 2D .0512
requirements, the bagfilters are required to have monthly visual ductwork inspections and annual internal
inspections. There are requirements to operate the wet electrostatic precipitator with at least two out of three
fields functioning. In discussion with Ms. Couts, she indicated that the data is available to monitor the number
of fields that have been operating. Ms. Couts indicated that the precipitator has been able to maintain at least
two fields operating in the unit.
The facility is required to perform weekly inspections on the burners, fans,blowers, and process control
equipment associated with the dryers. In addition, an annual internal inspection of the dryers is also required.
The facility is required to keep records of the monitoring activities and to submit a summary report every six
months documenting any compliance exceptions and summarizing total particleboard production. The 1"2018
semiannual report was submitted in time and indicated that all the monitoring had been performed throughout
the period. The facility appeared to be maintaining the required records.
(10) 1 SA NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING (CAM)—The following sources are
subject to CAM requirements:Biofilter (ID No. CD-18), PB surface layer dryer (ID No. 1430), PB core layer
dryer No. I (ID No. 1420), and PB core layer dryer No. 2 (ID No. 1410).
IN COMPLIANCE—The biofilter CAM requirements focus on operating the biofilter within a minimum and
maximum bed temperature range. These limits have not yet been established. A stack test is planned for
October 2018 to determine a wider bed temperature range. The PB CAM requirements focus on monthly
external visual inspections of the associated cyclones (CD-1411, CD-1421, CD-1431). The permit also requires
that the primary voltages and currents be monitored on the wet electrostatic precipitator(ESP). Records
indicated three voltage excursions and two current excursions in the first half of 2018, which is below the
Quality Improvement Plan(QIP)threshold of six each.
(11) ISA NCAC 2D.1109: Case by Case MACT- The following emission sources are subject to 2D .1109: The
thermal oil heaters (MDF Plant—ID Nos. ES-18, ES-19, ES- 20) and thermal oil heater(PR-Heat 1).
IN COMPLIANCE—The requirements of this regalatior�include a:.aruIual irLspectio.1 arld annual tune-up. The
MDF thermal oil heaters were inspected/tuned up on December 9. 2017. The PR-Heat 1 unit was
inspected/tuned on May 8, 2018.
(12) I5A NCAC 2D .I111:MA CT SUBPART DDDD—PLYWOOD AND COMPOSITE WOOD PRODUCTS-
The following emission sources are subject to 2D .1111:All of the permitted emission sources are potentially
subject to 2D .1111 except the thermal oil heaters (MDF Plant—ID Nos. ES-18, ES-19, ES-20), Emergency
Generators (ID Nos. ES-21, ES-ODG), Fire Pump (ES-DFP-1) and the Laminator Mill emission sources.
IN COMPLIANCE—The facility chose to comply with this regulation by adding a control system to reduce the
hazardous air pollutants (HAP) generated by the processing of composite wood products. The facility had
selected a Photocatalytic Gas Treatment(PGT) system for both the particleboard plant and the MDF plant.
These systems proved fairly effective for removing methanol and formaldehyde from exhaust streams. Over
the course of the past few years, safety concerns over the UV lights, hydrogen peroxide, and nitric acid grew to
the point where the facility began to investigate optional control systems. Presently, the facility is under an
SOC that was signed on November 2, 2015 to allow the facility to consider options for meeting the
requirements of this rule. A pilot study for the particleboard plant resulted in the facility choosing to use a
production-based compliance option with no controls. The facility has submitted a permit application for this
option. For the MDF plant, a biofilter was selected as the add-on control for HAPS of concern and start-up of
the unit was in February 2018. The NOCS for the biofilter was dated August 10, 2018 and received at DAQ on
August 13, 2018. The biofilter is still in the testing process. The facility provided an SDS sheet by email on
April 2, 2019, which showed that non-HAP coatings are used.
The facility is additionally required to have a Startup, Shutdown, and Malfunction Plan(SSMP) developed by
October 1, 2008. In the past,this facility has been able to show that a completed SSMP is maintained at the
facility related to the previous control equipment. Another SSMP will have to be developed for this new
equipment.
(13) 15A NCAC 2D.1111:AM CT SUBPART ZZZZ—RECIPROCATING INTERNAL COMBUSTION ENGINE
-The following emission sources are subject to 2D .1111:Emergency Generator(ID No. ES-21), and
Emergency Generator(ID No. I-ODG).
IN COMPLIANCE—I-ODG is rated at 465 horsepower(hp) and is located at the particleboard plant. The
generator has the required non-resettable hour meter installed on it. The facility also has performed the
necessary annual maintenance on this generator. The hour meter registered 488 hours.
The emergency generator(ID No. ES-21,rated at 1592 hp) is located at the MDF plant. Due to its size, this
generator has no requirements under this MACT. The hour meter registered 405 hours during the September
26, 2017 inspection and 546.7 hours during this inspection.
The facility presented generator maintenance logs for both generators.
(14) 15A NCAC 2D.1111:MACT SUBPART DDDDD—BOILERS AND PROCESS HEATERS- The following
emission sources are subject to 2D.1111: Wellons (ID No. 3201) when operating in OS-2.
IN COMPLIANCE—Operating scenario (OS-2) characterizes this unit when combusting natural gas. This
heater has been historically fueled by hog waste wood and presently the unit is utilizing a newly installed
natural gas burner. The initial tune up and one-time energy assessment were due by January 31, 2016.
According to the previous inspection report, the energy assessment on the Wellons Unit was done in April 2014
and was a part of the project to scope out and convert the unit to natural gas. Per EPA's online Central Data
Exchange (CDX) archived documents, the initial tune-up on the Wellons Unit was done in July 2015.
However, this tune-up did not meet the requirements listed in 40CFR 63.7540(a)(10)(i-vi) according to the
compliance report. The facility conducted a subsequent tune-up, which did meet requirements, on November
30, 2016. The MACT compliance report was archived in CDX on 1/24/2017. Onsite recordkeeping indicated
that the most recent tune-up was done on November 20, 2017.
(1 S) 15A NCAC 2Q Q.0317: CONDITIONS TO A VOID PREVENTION OF SIGNIFICANT DETERIORATION
(PSD):All of the following emission sources are subject to the PSD avoidance limitation:MDF Plant.
IN COMPLIANCE— To avoid applicability of the 15A NCAC 2D .0530 PSD regulations for the MDF plant,
the facility is required to limit the emissions of NOx, VOC, PM-2.5, and PM-10 to the following respective
annual limits (tons): 177.8, 337, 111.9, and 116.9. To establish these emission rates, performance tests were
performed. Some of the testing occurred in May 2011 and June 2011. The testing was not completed until
November 2011. The final test results were submitted in January 2012 and were reviewed/accepted by the
Stationary Source Compliance Branch. The tests were to determine if the MDF plant emission rates exceeded
the following limits: NOx—33.88 lb/hr, VOC—54.28 lb/hr, PM10—9.5 lb/hr, PM2.5- 9.5 lb/hr.
The permit additionally requires that a solution of urea/water(45%urea concentration(by volume))be injected
into the Energy System at a minimum rate of 0.24 gpm(3-hour block average). This is to help control of-NOx
emissions. The injection rate was increased from 0.11 gpm to 0.24 gpm in May 2015 with permit revision T44.
Review of facility records indicate that the required PSD monitoring was performed as required.
The facility is also required to monitor the process rates of dryers in ODT/hr(oven-dried ton/hour), the press
process rates (MSF/hr), and heat input for the combustion sources. The facility is keeping track of these
parameters.
The facility is also required to determine what the 12-month rolling total MDF emission rate for PM-10, PM-2.5
and NOx, and report it on a semiannual basis. Previously, the facility reported emission rates to the Raleigh
Regional Office quarterly. The most recent report (1st 2018 semiannual) indicated that highest 12-month rolling
total over that six-month period for each of these three types of pollutants is as follows: PM-10—84.1 tons, PM-
2.5 —83.3 tons, and NOx— 130.5 tons. Note: the facility is exceeding its VOC limit since no controls are in
place until the biofilter testing period is completed. The facility is operating under the terms of an SOC
covering this exceedance.
(16) 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the facility's
permitted emission sources are subject to 2D.1806.
IN COMPLIANCE -To comply with 15A NCAC 2D .1806, the permittee shall not cause, allow, or permit the
facility to be operated without employing suitable measures for the control of odorous emissions. No
objectionable odors were noted during the compliance inspection. No citizen odor complaints have been filed
against the facility in the past 10 years. There was one complaint lodged in August 2006 concerning a citrus
smell that burned the nose of the complainant. The subsequent odor investigation did not substantiate the
complaint.
(VI) EXEMPT EMISSION SOURCES: All sources currently listed on the facility's insignificant activities
attachment to the permit have been observed during past inspections. No additional exempt emission sources
were noted that would need inclusion on the permit's insignificant activities list.
(VII) 112R APPLICABILITY: The facility does not appear to have threshold amounts of listed compounds to
be subject this program.
(VIII) STACK TEST REVIEW: The PB surface layer dryer(ID No. 1430) and one of the PB core layer
dryers(ID No. 1420) was tested in October 22, 2009 and the results from this testing demonstrated that
particulate emissions, volatile organic compounds, visible emissions, carbon monoxide, and nitrogen oxides
from the operating PB dryers were below the BACT standards. Some tests of the MDF facility started May
2012, occurred again in June 2012, and continued into November 2012. The particleboard plant testing was
performed in December 2012, January 2012, and in March 2012. There is an annual particulate testing
requirement for the Energy System(ES-02-A). There was a particulate test performed on the MDF Energy
System on November 29, 2012 and a test performed on October 23, 2013 with the results which indicated
compliance. A stack test of the MDF Energy System was performed on November 4, 2014 indicating
compliance to the NO, and particulate limits. These tests were performed with the PGT systems actively
controlling emissions. The PGT systems have been shut down and removed. On January 14, 2016, the facility
tested the particleboard press4o determine selected ketone, aldehyde, and polar compound levels when the
emissions were uncontrolled. On June 12, 2018, the particleboard press vent (DEF-2010)was tested for HAP
to satisfy testing requirements of 40CFRPart63 DDDD and the test failed. The press was retested on July 19,
2018 and showed compliance. On July 24, 2018, the drum dryers (1420, 1430) and Wellons Unit (3201) were
tested for VOCs according to 2D .0503 Best Available Control Technology(BACT) limits and compliance was
shown. On July 25, 2018, the biofilter was tested for PM and NOx according to 2Q .0317 PSD Avoidance
requirements and compliance was shown. On June 13, 2018, inlet/outlet air emissions testing was conducted on
the biofilter(CD-18), which controls emissions for the Refiner(ES-01), the Energy System (ES-02-A), a Two-
Stage Dryer System (ES-02-B), two Back-up Dryers (ES-02-C & ES-02-D), the MDF Board Cooler and Press
Hall (ES-06-B) and the MDF Press (ES-16). The testing demonstrated compliance with the emission limits of
NCAC 2D .1111 MACT, 40 CFR Part 63 Subpart DDDD,National Emission Standards for Hazardous Air
Pollutants: Plywood and Composite Wood Products and fulfilled a portion of the requirements of Special Order
By Consent (SOC 2015-02). The MDF operations controlled with the biofilter is scheduled to be tested on
October 18, 2018 with the purpose of widening the bed media temperature range per the Plywood MACT
(DDDD).
(IX) EMISSION INVENTORY REVIEW: The difference in facility emissions comparing 2015 and 2016
calendar years were explained in the review of the 2016 emissions inventory. Specifically, the following text
was provided: "Criteria, toxic, and HAP pollutant reductions are attributed mainly to less oven dried tons in
particleboard dryers in 2016. Toxic/HAP emission increases due to higher MMBtu/yr combustion of Hog fuel
and Sanderdust combustion in Particle Board plant. Increase in formaldehyde emissions are from a change in
emission factor(1.181b/ODT) due to the shutdown of the Photo gas chemical treatment(PGT) of MDF Plant
Dryer on October 23, 2015 due to a Special Order of Consent(SOC) received by facility. According to
NCDAQ policy, for OS-51, Arsenic Compounds-Arsine gas and Chromium (VI)Non-Specific were recoded to
ASC-Other and Chromic Acid (VI) (7738945), respectively."
(X) ENFORCEMENT HISTORY: An NOV/NRE was issued on April 20, 2017 detailing additional numerous
instances of operational (monitoring) violations beyond those addressed in the previous NOV/NRE. An
NOV/NRE was issued on October 12, 2016 to address numerous instances of operational (monitoring)
violations. On November 2, 2016, an SOC was issued to the facility regarding the shutdown of the PGT
systems on September 20, 2015. An NOV was issued regarding this shutdown on October 23, 2015. Arauco
has previously been issued two Notice of Violations (NOV) and nine Notices of Violation/Notices of
Recommendation for Enforcement(NOV/NRE) according to DAQ records. An NOV/NRE was issued on
March 12, 2013 for various monitoring and operational issues with an associated fine of$23,574. An
NOV/NRE was issued on May 3, 2012 for various recordkeeping/monitoring violations with an associated fine
of$20,774. An NOV/NRE was issued on April 12, 2012 for a visible emissions violation and two releases of
uncontrolled emissions. On November 14, 2011, an NOV was issued due to a late submission of a Part II
portion of an air permit application. An NOV/NRE was issued on February 17, 2011 for missing test deadlines,
and operating equipment with compromised or inoperative control equipment. The civil penalty for the
February 17, 2011 was $42,571. An NOV/NRE was issued on May 4, 2010 for not preparing a Startup,
Shutdown, and Malfunction Plan. Enforcement was not pursued on the May 4, 2010 NOV/NRE. An
NOV/NRE was issued on March 4, 2010 for a reporting violation with an associated fine of$1228.00. An
NOV/NRE was issued on August 12, 2009 for not performing a stack test by the due date with an associated
fine of$4292.00. On October 22, 2008, an NOV was issued for both a late 1st semiannual report and a late 2nd
quarter report for 2008. On May 3, 2006, the facility was issued an NOV/NRE for operating the particleboard
dryers without the associated regenerative thermal oxidizer online. The company entered a Special Order by
Consent to resolve these violations and paid $37,500 in settlement fees. On April 11, 2003,the facility was
issued an NOV/NRE for-operating the particleboard dryers without the associated regenerative thermal oxidizer
online with an associated fine of$4219.00. On August 23, 2002, the facility was issued an NOV/NRE for an
annual emissions reporting violation with an associated fine of$1000.00.
(XI) CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the inspection, the
facility appears to be in compliance with the exception of the ongoing violations covered under the 2015 SOC.
It is recommended that an annual inspection be performed within the next 12 months.